ML20195G520

Responds to Request for Review & Comments on Whether or Not Technically Acceptable Inerted Containment Sys Could Satisfy Provisions of 10CFR50.44(g).NRC Awaiting plant-specific Submittals on Compliance,Per 870120 Meeting

ML20195G520
Person / Time
Site:	Quad Cities
Issue date:	08/31/1987
From:	Dorian T NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Janecek R BWR OWNERS GROUP, COMMONWEALTH EDISON CO.
Shared Package
ML20151T837	List: ML20151T833 ML20195G520
References
NUDOCS 8709300402
Download: ML20195G520 (2)

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Mr. Robert F. Janecek, Chairman BWR Owners' Group g/

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Rm. 34 FN East P.O. Box 767 Chicago, ll 60690 Re:

BWROG-8737 inarted Contalmnment Systems

Dear Mr.,

Janecek:

You recently sent me a letter requesting my review and written comments about whether or not a technically acceptable Inerted containment system could satisfy the provisions of 10 CFR 50.44(g).

In that letter you stated that "BWROC maintains that paragraph 50.44(g) does not preclude the use of a technically acceptable inerted contalament system to satisfy combustible gas control requirements" and that "BWROG submits that 10 CFR 50.44(c)(1) may be satisfled by an inerted containment system."

We have reviewed your analysis and are prepared to agree that, on balance, it is reasonable to interpret 10 CFR 50.E'(g) and 50.44(c)(1) so as not to preclude an inerted centainment system from satisfying these regulations, provided the Inerted containment system is Indeed found to be technically acceptable.

The nessure of "acceptability" must be high, however -- as I explained to you a few days ago over the phone, a "bare bones" measure will not suffice because the staff's evaluations of the technical merits of licensen' submissions involve plants that are not of the most recent vintage as well as some of the most complex and difficult issues in the pt evention and mitigation of accidents highlight'ed by the accident at Three Mlle Island.

With respect to the issue of technical acceptability, staff members of the Office of Nuclear Reactor Regulation held a meeting on January 20,1987, in Bethesda, Maryland, with representatives from GPU Nuclear, Commonwealth Edison, Northeast Utilities, and Nebraska Public Power Distrlet on the j

systems used in their Mark I containment plants for combustible gas control.

I believe a summary of that meeting was sent to each participant in late April,1987.

Thu summary called for each licensee to submit its plant-specific position about its compliance with IC CFR 50.44(g) on a schedule to be i

determined with N R R's project managers; that position, by the way, was supposed to be the licensee's Justification of the reliability of its containment inorting system.

The submittal was to include a discussion of the j

assumptions made by the licensee to justify its position on 10 CFR 50.44 (the staff's position was and continues to be that Regulatory Culde 1.7 should be used to calculate the generation of combustible gases during a loss of coolant accident and that the submittal of lortheast Utilities is unacceptable at:

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present), the information discussed during the meeting on the reliability and (gy oclSocMC D 6 CF-

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3-capability of the containment inerting system and on the window of accident sequences for which this system would be effective in controlling combustible gases, and an analysis of the time period and the licensee's actions needed for the existing syster) to respond to the increasing combustible gas e

concentrations in the containment from radiolysis of water before the acceptable limits are exceeded.

I have discussed this matter with the cognizant NRR staff, and we are now awaiting the licensees' submissions.

I hope that this addresses your concerns, if you have any questions or wish to discuss the matter further, please feel free to call me at (301) 492-8690.

Sincerely, Thomas F. Dorian Office cf the General Counsel DISTRIBUTION:

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